Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $51,996.74 for 1981 and $8,103.50 for 1982. After concessions, the issue remaining for decision is whether Forms 872-A executed by petitioners to extend the statute of limitations on assessments for 1981 and 1982 bar the use of the correct base period adjusted income amounts in determining petitioners' eligibility for the income...
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